Consultation response
Autumn 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response
This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.
10 - Identification and verification
Applying CDD measures involves several steps. The casino operator is required to identify customers and then verify their identities, either upon establishing a business relationship, upon entry or when reaching the threshold. Identification of a customer means being told or coming to know of the customer’s identifying details, such as their name and address.
Verification means proving a customer is who they claim to be by obtaining and validating documents or information which supports this claim of identity. The operator identifies the customer by obtaining a range of information about the customer. The verification of the identity consists of the operator verifying some of this information against documents, data or information obtained from a reliable and independent source.
Identification
Identification of customers consists of a number of aspects, including:
- the customer’s name
- current and past addresses
- date of birth
- place of birth
- physical appearance
- employment and financial history
- family circumstances.
Casino operators should identify their customers by asking them for personal information, including name, home address and date of birth, or by using other sources of identity, including:
- identity documents, such as passports and photo card driving licences presented by customers
- other forms of confirmation, including assurances from persons within the regulated sector (for example, banks) or employees within the same casino or casino group who have dealt with the customer for some time.
It may also be helpful to obtain information on customers’ source of funds and level of legitimate income, for example their occupation. This information may assist casinos with their assessment about whether a customer’s level of gambling is proportionate to their approximate income, or whether it is suspicious.
Verification
Information about customer identity must then be verified through documents, data and information which come from a reliable and independent source.
There are a number of ways that a person’s identity can be verified, including:
- obtaining or viewing original documents and ensuring that they are valid and genuine, by comparing them to published, authoritative guidance that outlines security features (which protect against forgeries)
- comparing the person presenting the document, or making the document available, to the document itself (for example, photograph comparison or comparison of information)
- conducting electronic verification through a scheme which properly establishes the customer’s identity, not just that the customer exists
- obtaining information from another person in the regulated sector (for example, from banks), that can be used in conjunction with other documents and information to prove a customer’s legitimacy over time, or positive or negative information.
No method of documentary or electronic verification can conclusively prove that the customer is who they claim to be
However, the Commission expects casinos to be reasonably satisfied, following appropriate inquiry, that customers are who they claim to be. Where confirmation of a customer’s identity is obtained from employees in the same casino group, the Regulations still require casino operators to verify this identity using an independent source. This is particularly relevant where the casino providing the confirmation is located in another jurisdiction.
Good practice
It is considered good practice to request the following evidence from a customer:
- one document from an authoritative source110 that verifies their full name and address, or their full name and date of birth
- one supporting document that verifies their name and either their address or date of birth, whichever was not checked on the first document. Where the evidence provided by the customer is photographic, operators should conduct a comparison of the customer to the evidence provided.
Celebrity status
Some casinos have adopted the practice of allowing celebrities who are household names to by-pass the identification procedures agreed under the 2003 Regulations. Identification under these circumstances is not an issue. Verification may not be an issue owing to the easy availability of open source data and public knowledge that can be relied on as 'information from an independent and reliable source'. If such circumstances apply, then the casino must keep records of the celebrity’s presence at the casino, how their identity has been verified and, where necessary, the supporting records of their gaming.
The way in which CDD is conducted in relation to a customer’s celebrity status is a subjective decision and must be supported by adequate records, and, as with other cases, still requires the casino to be reasonably satisfied that the customer is who they say they are.
References
110An 'authoritative source' is an authority which has access to sufficient information from an issuing source to enable them to confirm
the validity of the information and/or documentation provided by the customer to support their claimed identity. An issuing source is an
authority that is responsible for the generation of data and/or documents that can be used as evidence of identity. Identity proofing and
verification of an individual guidance published by the Government Digital Service (opens in new tab)
Last updated: 30 May 2023
Show updates to this content
Updated in line with version 3 of the guidance. References to 'proliferation financing' added.